In Case You Missed It: A Closer Look at Assigning Summer Cross-Over Periods with Year-Round Pell, And Other Q&As

The Department of Education (ED) recently posted a Dear Colleague Letter giving guidance on the new year-round Pell Grant provision. NASFAA discussed that guidance, and related issues, with ED officials in advance of their participation in NASFAA’s National Conference. We share our understanding of some questions that have arisen below, which ED officials will address at the conference.

1. How must I assign summer cross-over periods, now that year-round Pell is back?

Only the authority to pay a student more than one scheduled award in an award year is back; there are no provisions that change an institution’s flexibility to assign summer cross-over periods to either the concluding year or the upcoming year. For example, an institution may assign a summer session that crosses over July 1, 2017, to the 2016-17 award year in all cases as a matter of policy, or always to the 2017-18 award year, or individually on a case-by-case basis. This guidance will continue to apply.

The new provision in the law directs the Department of Education (ED) to allow an institution “to determine the award year to which the additional [cross-over] period shall be assigned, as it determines is most beneficial to students.” In its explanatory material, Congress further clarifies that ED “should implement this provision to maximize flexibility for institutions of higher education and avoid unnecessary administrative burdens while ensuring the best interests of students.”

In Dear Colleague Letter GEN-17-06, posted on Monday, ED encourages institutions to decide on the award year assignment “based on what is in the best interest of the student and maximizes the student’s eligibility over the two award years.” This text continues current guidance in the 2016-17 FSA Handbook (p. 3-46 and 3-58), which assures institutions that they are not “required to assign a crossover payment period to the award year in which the student would receive the greater Pell award, but are free to assign crossover payment periods to the award year that best meets the needs of your students and maximizes a student’s eligibility over the two award years in which the crossover payment period occurs.”

Thus, the institution may assign, or reassign, summer to either year for an individual student, regardless of its standard policy. This is not a professional judgment decision; it is simply an available option. For a student who is attending a 2017 summer session that crosses over July 1, and who exhausted her 2016-17 Pell Grant during the regular academic year, the institution can fund her by assigning summer to 2017-18. Doing so will no longer result in a shortage of funds in the spring, since the new year-round Pell provision will allow access to additional funds.

2. Can I award more Pell Grant funds from a student’s 2016-17 need analysis for summer 2017 if the student has already received the full 2016-17 scheduled award?

No, you cannot exceed a single scheduled award from 2016-17 eligibility. For 2016-17, including any summer cross-over periods (i.e., enrollment periods that encompass July 1) that the school assigns to 2016-17, a student is still entitled to only one scheduled award. Since a scheduled award is the amount that a full-time student would receive for a full academic year, if a student has remaining funds from 2016-17 because he did not attend fall and spring on a full-time basis, those funds are still available for his use during summer 2017.

3. How much “extra” Pell can I award a student?

A student may receive up to 50% of an additional scheduled award within an award year, for extra payment periods attended. For example, a student attends full-time fall and spring, fully utilizing the initial scheduled award. If the student attends summer full-time, the institution may pay a full-time award, as that would be 50% of the scheduled award for the year.

Note that funds from the additional scheduled award may be used to “top up” a Pell payment if the student is eligible for more than is remaining from the initial scheduled award. GEN-17-06 provides an example of this procedure, which financial aid administrators may remember from the previous year-round Pell iteration.

4. Are there any special eligibility requirements a student must meet for year-round Pell?

Although there are no “acceleration” criteria, the student must be enrolled at least half-time for the payment period in which any funds in excess of the first scheduled award will be used. For example, a student attends full-time in the fall and 3/4-time in the spring in 2017-18. He decides to attend the summer 2018 to make up the deficit coursework. If he enrolls for just one class and the institution considers that less than half-time, he can still use any remaining funds from the initial award. If he increases his course load to at least half-time, he could be paid the remaining first scheduled award, plus funds from an additional scheduled award.

If that student had already been paid a full scheduled award for full-time time attendance in both fall and spring, he could not be paid for less than half-time attendance based on 2017-18 eligibility, but he could be paid from 2018-19 eligibility if the summer term crosses over July 1, since it would be the first payment from an initial scheduled award for that year and no minimum enrollment status is required for the first scheduled award.

5. What changes to current policy will year-round Pell bring?

Essentially, there are no changes to current policy. The FSA Handbook gives the following guidance, which will continue to apply:

You must consider a crossover payment period to occur entirely within one award year and calculate the student’s Pell award and disburse Pell funds from the award year selected (if you only have a valid SAR/ISIR from one award year, you must rely on that record and the award year to which the valid SAR/ISIR pertains).

You may assign the Pell award to a different award year than the rest of the student’s Title IV aid.

You can make a payment for a crossover payment period out of either award year, if the student has a valid SAR/ISIR for the award year selected.

You may assign two consecutive payment periods to the same award year. For example, you could treat summer 2017 and summer 2018 as both being in the 2017-18 award year.

Keep an eye out for AskRegs articles from NASFAA on Pell Grant administration and summer packaging considerations. More information will be posted in Today’s News as it is attained.

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